Sanact, Inc. v. U.S. Pipelining LLC
1:16-cv-00377
D. Haw.Sep 10, 2018Background
- Sanact, Inc. dba Roto Rooter obtained a district-court judgment against US Pipelining LLC for breach of contract: $123,203.16 plus prejudgment interest (totaling $155,603.97). The district court found Sanact the prevailing party under Haw. Rev. Stat. § 607-14.
- Sanact moved for attorneys’ fees and related non-taxable expenses under § 607-14. US Pipelining stated it would not oppose the motion.
- Plaintiff sought $37,614.00 in attorney/paralegal fees plus $1,567.00 in general excise tax (total $39,181.00) and $504.14 in non-taxable travel expenses.
- The magistrate judge applied Hawaii’s fee-reasonableness framework (akin to the federal lodestar method), evaluating reasonable hourly rates and reasonable hours expended.
- The court found the requested hourly rates and hours reasonable (including somewhat higher paralegal rates given the work performed), calculated a lodestar of $37,614.00 plus $1,567.00 tax, but limited the award to the statutory cap of 25% of the judgment.
- The court recommended awarding $38,900.99 in attorneys’ fees/taxes (25% cap) and $504.14 in non-taxable expenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to fees under Haw. Rev. Stat. § 607-14 | Sanact is prevailing party entitled to reasonable attorneys’ fees under § 607-14 | US Pipelining did not oppose fee recovery | Court: Sanact entitled to reasonable fees under § 607-14 (prevailing party) |
| Proper method to determine reasonable fees | Use lodestar-style analysis (reasonable rate × reasonable hours) and factors (novelty, community rates) | No opposition to method; court should assess reasonableness | Court applied lodestar approach (instructed by Hawaii law and federal precedent) and found rates/hours reasonable |
| Hourly rates and hours billed (including paralegal rates) | Requested rates for attorneys and paralegals are reasonable based on prevailing community rates and work performed | No objection from defendant | Court found requested attorney and paralegal rates and hours reasonable given the record; paralegal work justified higher rates here |
| Statutory 25% cap on fee award | Seek full reasonable fee amount (which exceeded 25% cap) | No opposition to fees but statutory cap applies | Court limited fee award to 25% of total judgment: $38,900.99 |
| Award of non-taxable expenses | Travel expenses to attend settlement/pretrial ($504.14) were reasonably incurred and should be awarded | No opposition | Court recommended awarding $504.14 in non-taxable expenses |
Key Cases Cited
- Hensley v. Eckerhart, 461 U.S. 424 (lodestar method for reasonable attorney fees)
- Webb v. Ada Cnty., 285 F.3d 829 (9th Cir.) (use prevailing community rates for hourly rate determination)
- Gates v. Deukmejian, 987 F.2d 1392 (9th Cir.) (exclude excessive, redundant, or unnecessary time)
- Jordan v. Multnomah Cnty., 815 F.2d 1258 (9th Cir.) (fee applicant must submit evidence supporting requested rate)
- DFS Grp. L.P. v. Paiea Props., 131 P.3d 500 (Haw. 2006) (Hawaii courts’ lodestar-like approach)
- Chun v. Bd. of Trs. of Emps.’ Ret. Sys. of Haw., 106 P.3d 339 (Haw. 2005) (factors including novelty and community charges relevant to fee reasonableness)